The Association of Member Episcopal Conferences in Eastern Africa (AMECEA) owes immense gratitude and appreciation to various people whose contribution in various ways made this endeavour a resounding success.

First, we owe a great sense of appreciation to Mr. Tony Moturi, the consultant who steadfastly carried out this baseline study. For his time, diligence and incisive analysis, we thank him for using his competence and expertise to point us in the right direction.

To the participants at the validation workshop who subjected the initial draft of this baseline study to a rigorous analysis and critic. It is through their input that this research output became a coherent and admissible document for our consumption.

We must also thank the AMECEA staff: Programmes Coordinator; Father Jude Waweru and Pauline Wakibiru, for their invaluable and diligent commitment to making this a success right from the inception level of the project, to every step of its management and liaison with the key actors; they made this process less strenuous.

We are eternally grateful to our project partners, Catholic Agency for Overseas Development (CAFOD) for their unwavering faith in our work and their continued and consistent support for it. It is their financial resource support that ultimately made this project a reality.

To those who played key roles and are not mentioned, it is not a deliberate omission. We take cognizant and a profound appreciation for your contribution. It is our pleasure to present this research study report to you and hope that you will find the contents of immense usefulness and timely.

AMECEA JUSTICE AND PEACE DEPARTMENT

EXECUTIVE SUMMARY

At the heart of economic development, countries such as South Africa, Nigeria, Democratic Republic of Congo and recently East African countries have sought to expand their economies largely from extracting mineral endowments. In South Africa, successes have been registered with enormous economic growth, while in others, large populations fight to survive inequities.

This research zeros on the extractive industry in Kenya and Uganda in areas of Kwale County in Kenya and Karamoja in Uganda.

It exemplifies the rights of people eking a life in these areas from the extractive industry, probes the status quo and establishes the intended interventions in policy and practice.

The study also roots for the nexus between the efforts of the church in advocacy and the needs for intervention by other stakeholders outside the daily practices in the mines.

It interrogates the duty bearers and the primary actors in the industry by looking behind the veil to identify the policy gaps and individual company activities which are contributory to the reissues faire in these regions.

The methodology used factored in sentiments of 65 community members 39 in Kwale region in Kenya and 28 in the Karamoja region who live in the exploration and mining license areas. The data collected through review of secondary sources (desk review), structured interviews; key informant interviews; and focus group discussions has been analyzed and verified with the featured companies; Base Titanium, East Africa Mining Ltd, Jan Mangal Ltd and DAO Uganda Ltd to build a track towards the final recommendations.

Universal standards are visited upon the finding to establish the fulcrum on which the mining practices in Kwale and Karamoja should auspices.

It is expected that a more intensive study shall be conducted with the intent of finding the intricate issues of welfare and labor policies of the miners and the place of the church in bolstering community awareness and synergies.

1.0. INTRODUCTION AND BACKGROUND

1.1. The Basis of the Study

Managing natural resources for development is challenging. Many countries with large endowments of valuable natural resources and strong governance structures do no better, and often do worse, than less endowed countries. This recurrent fact has been called the “natural resource curse” or the “paradox of plenty”. Yet, the natural resource curse is not inevitable. Some countries have been able to effectively manage natural resources to advance their development. Problems abound from community participation, sharing of proceeds from the extractive industry and injustices meted to workers in the mines as well as land owners on whose property the mines are found.

A recent World Bank study, Africa’s Pulse,[1] compared growth of Africa’s resource-rich and non-resource-rich countries between 1980 and 2010. In the 1980s, both sets of countries experienced a virtual stagnation in per-capita gross domestic product. Overall, resource-rich countries were unable to harness resource wealth in the first two decades. Since 2000, however, it has been a different story: higher growth in all groups, with oil-rich countries in the lead. Despite this growth, less impact has been felt on reducing poverty levels. In converse, there has been an increase in the percentage of their population living in extreme poverty.

Countries in the East Africa region are not an exception either. Most of these resources have not been used to benefit the local communities. Despite the wealth associated with mining, most communities wallow in poverty.

With the new discoveries of natural resources in several countries in the region including Kenya, Uganda and Tanzania- it raises an important question: Will these windfalls be a blessing that brings prosperity and hope, or a political and economic curse, as has been the case in so many countries?

It is against this background that AMECEA Peace and Justice Desk sought to investigate, identify and seek ways to address injustices meted against communities that leave within the mining belts in Kwale and Karamoja regions.

1.2. Objectives

Through this project, AMECEA Peace and Justice Department sought achieve the following:

· Assess the current situation as regards to the extractive industry in the two countries with a view of identifying areas of entry and convergence that the Catholic Church could use in its advocacy work

· Assess the existing community participatory structures in the extractive industry

· To establish clear indicators of baseline(s) in local communities’ participation and transparency of governments and mining companies that will be used to generate data for evidence based decision making

1.3. Methodology

The baseline survey used a variety of sources and methods to collect the information. The following techniques were used; review of secondary sources (desk review), structured interviews; key informant interviews; and focus group discussions. The participation of women, youth and minorities was specifically sought in the whole process.

In total the researcher interviewed 65 community members 39 (20 men and 19 women) in Kwale region in Kenya and 28 (16 men and 12 women) in the Karamoja region who live in the exploration and mining license areas.

The companies featured in this report are Base Titanium, East Africa Mining Ltd, Jan Mangal Ltd and DAO Uganda Ltd.

The researcher discussed with all interviewees the purpose of the interview, its voluntary nature, the ways the information would be used, and that no compensation would be provided for participating.

The researcher sent letters to senior management of each company. Out of the four companies, only Base Titanium that responded through phone interview and all correspondence is available in the annexes to this report.

1.4. Study Limitations and Challenges

Cooperation of Government Officials as well as Company Management: although sufficient inquiries were made to government officials as well senior managers of the companies who were unwilling to freely provide for interviews and key documents. The study sought to mitigate this challenge by seeking more information from the internet and reports from different organisations on this subject matter.

Time and geographical Constraints: The period allocated for this study was limited comparing the vast areas that were understudy. It was therefore important for the survey to proceed with speed by employing means of transport such as hired motorbikes to reach outlaying locations which were inaccessible by public means.

Budget Constraints: The survey budget was limited and this necessitated a rethink of the original research design so as to fit the available funds. Only 4 days of field data collected could be supported by the available budget. Use of rapid qualitative methods of data collection (FGDs and Key Informant interviews) was therefore found necessary. This led to the omission of the mine workers from the study.

On overall, the limitations and challenges did not have any considerable effect on the quality of data obtained.

2.0. POVERTY AND SURVIVAL

2.1. Introduction

Most potential mine sites in the region are found in places where the poor live, and they are mostly indigenous peoples. These poor communities have few economic alternatives and generally survive on subsistence farming. Most of the residents understand this activity will never get them out of poverty, but also understand that the wealth underneath their land, if properly harnessed, can give them the chance to break out.

Kwale County is one of the six counties in the former Coast Province. The County covers an area of 8,322 km2 of which 62km2 are under water. It is bordered by Taita Taveta county to the West; Kilifi county to the North; Mombasa county and Indian Ocean to the East and United Republic of Tanzania to the South.[2]

The 2009 Population and Housing Census showed that the County had a population of 649,931 in 122,047 Households where 74.9% of the population live below the poverty line.

The better off households are concentrated in Kubo and Matuga while the poorest are concentrated in Kinango and Samburu, and to a lesser extent in Msambweni Divisions.

The major causes of poverty in the County include the poor infrastructure development including electricity, roads, telecommunications and water, inadequate agricultural production due to land tenure problems, poor and undeveloped agricultural marketing and wildlife menace.

The remote Karamoja region of north-eastern Uganda, stretching across 10,550 sparsely populated square miles, accounts for nearly 10 percent of the country.[3] It is home to an estimated 1.2 million people spread across seven districts—Abim, Amudat, Kaabong, Kotido, Moroto, Nakapiripirit, and Napak.

While the ethnic groups who live in Karamoja are sometimes referred to collectively as Karamojong,[4] the majority constitute three distinct large groups: the Dodoth to the north in Kaabong district; the Jie in the center in Kotido district; and the Karimojong (comprised of the Matheniko, Bokora, and Pian) to the south in Moroto and Nakapiripirit districts. Othersmaller groups include the Pokot, Ik, Tepeth, and Labwor.

2.2. Livelihoods, Marginalisation and Discrimination

Marginalisation is a consequence of a skewed process of the distribution of scarce resources; it has been interpreted as a process of social exclusion from the dominant socio-economic, cultural and political structure.

One of its features is manifested in land. Land ownership is a major problem facing the people of Kwale where most land owners do not have title deeds. In addition, there is a large proportion of the population without land while others are living as squatters in their own ancestral land after grabbing/allocation hence farmers are keen on developing their land (which would increase efficiency and production) due to fear of losing their investment.

The situation has been exacerbated by poor infrastructure development such as roads, provision of water and electricity, low agricultural production due to land tenure problems, poor and underdeveloped agricultural marketing, poor agro-industry base, vagaries of nature such as droughts and floods.

The peoples of Karamoja traditionally survive largely through a combination of pastoralism, agro-pastoralism, livestock-herding, and opportunistic agriculture to maximize the unfavourable environmental conditions and low annual rainfall. They occupy semi-permanent manyattas, the center of agricultural livelihoods, while cattle are traditionally kept in mobile or semi-mobile kraals. Failed or poor crops have occurred approximately one out of every three years, making livestock products an essential source of sustenance. Migration is a key element of this livelihood, allowing for the movement of herds between pasture areas in response to environmental pressures. Movements by some groups reach into Kenya and neighbouring regions of Uganda.

Successive Ugandan governments have viewed Karamoja as “backwards” compared to the rest of the country, largely because of the reliance on agro-pastoralism. The Idi Amin regime subdued the region by force, and subsequent former Prime Minister Apolo Milton Obote—famously quoted as having said “We shall not wait for Karamoja to develop”—created the Karamoja Development Agency to try to tackle development in the region. Government pressure to modernize and transform Karamoja continues in current political discourse.[5] In March 2009, when President Yoweri Museveni appointed his wife, Janet Museveni, as minister of state for Karamoja, he spoke of the need to “develop one of the backward areas” of Uganda.[6] Mrs. Museveni herself has spoken of needing to transform “the primitive and poor quality” lives in Karamoja.[7]

Despite government efforts to centrally control the peoples of Karamoja and “transform” their traditional lifestyle, infrastructure and services in the region, including schools, health centers, potable drinking water, roads, and many other facilities, are scarce. Large swathes of Karamoja are not yet on the national power grid.[8]

2.3. Poverty, Food Insecurity and Environmental Degradation

The mega project in Kwale, apart from resettling the displaced people, has over time destroyed indigenous Kamba and Digo subsistence farming. This in essence means the project will affect most fertile lands in the County that could no longer be cultivated as a result of the profound changes to the soil structure and as a consequence this will exacerbate food insecurity in the area. It will also have negative impact on the biodiversity of the area and there are serious concerns about other environmental impacts that are yet to be settled to the satisfaction of all stakeholders.

Extraction activities would also cause radioactive impacts, as large quantities of radioactive uranium and thorium were detected in the titanium deposits.[9] According to reports, the deposit contained 309 ppm 9parts per million) of uranium and 143 ppm of thorium which, if extracted, would be potentially dangerous for human health and the environment.

The project would alter the local ecosystem, jeopardising the survival of several species already at risk, such as the Colobus monkey.

Karamoja has the lowest human development indicators in Uganda, and approximately 82 percent of the population lives on less than $1 a day, whereas the national rate is 31 percent.[10] The region’s rough terrain and unpredictable rainfall have, in the past, resulted in severe climate variability, and in turn contributed to the region’s extreme poverty.[11] In 2006 there was serious drought; a combination of a prolonged dry spell and flooding in 2007; another drought in 2008; and 970,000 people were in need of food aid in 2009.

Furthermore, growing environmental problems are having a greater impact on the precarious position of poor households. Climate change, deforestation, soil erosion, and desertification are all impacting harvest and production capacity of agro-pastoralists.

Entrenched poverty and environmental variability has, over the last generation, increasingly pushed people into artisanal and small-scale mining for the region’s minerals, particularly gold and marble, for survival.

A June 2013 food security analysis, led by the Ministry of Agriculture, Animal Industry and Fisheries, revealed that up to 975,000 people in Karamoja face serious levels of food insecurity, while 234,000 more cannot meet their minimum food needs, and some districts recently experienced acute malnutrition rates.[12]

3.0. LAND AND RESOURCE RIGHTS

3.1. Right to Land and Development

Indigenous peoples have the rights to “own, use, develop, and control the lands, territories and resources that they possess by reason of traditional ownership or other traditional occupation or use, as well as those which they have otherwise acquired,” and to determine their own development priorities and strategies.[13] In order to realize these rights, states are required to give legal recognition and protection to these lands, territories, and resources, with due respect to the customs, traditions, and land tenure systems of the indigenous people concerned.[14]

Under the right to development, the Kenyan and Ugandan governments are obligated to ensure that the people in the mining areas are not left out of the development process or benefits. According to the African Commission on Human and Peoples’ Rights, the right to development is both constitutive and instrumental, and a violation of either the procedural or substantive element constitutes a violation of the right to development.[15] The procedural element requires active, free, and meaningful participation in development choices, free of coercion, pressure, or intimidation.[16] The substantive element should include benefit sharing, improve the capabilities and choices of people, and is violated if the development in question decreases the well-being of the community.[17] The combination of these elements should result in empowerment.[18]

In Kwale County, the inception of the mining project was bound to affect landowners located in Mwaweche and Kidiani locations and squatters located in Ramisi Sugar Estate. It is estimated that ther are about 450 households that have been affected. Of these, 25% are land owners with title deeds and 75% are squatters.[19] The average household size is about seven people per household, which means that approximately 3000 individuals have been affected.

According to Base Titanium,[20] various phases of resettlement have been undertaken since 2006, each conducted according to its own Resettlement Action Plan (“RAP”) prepared and implemented in collaboration with local committees including representatives of directly affected communities. Compensation was paid for land, agricultural crops, forest trees, structures and graves. Additionally requirements for livelihood replacement strategies and replacement land were provided. These RAPs were prepared in compliance with international best practice as stipulated in the IFC Performance Standards.

Affected households included 381 in the Special Mining Lease ("SML"), 112 associated with the Mukurumudzi Dam and 86 in the access road and water pipeline routes. Of these a total of 486 were physically relocated.

3.2. Voices of the Locals on Proprietary Rights

The Constitution of Kenya guarantees citizens the right to own property[21] and the State shall only take over land if it is for public purpose or in public interest and this should be accompanied by prompt payment and just compensation.[22]

Regulation of mining is based on the fact that all the natural resources, including titanium, existing in their natural state, are vested in the national government. As such, the national government is the body responsible for the conduct of mining operations in the country including licensing, exploration and mining. It has, however, emerged that the management of mineral resources, especially exploration and mining, poses great challenges for the state and local communities.

In Kwale, the locals whose land was acquired for mining purposes were paid ksh 80,000 way below the market value as it relied on valuations done in the 1980s.[23] The initial agreement was to be given alternative land on top of monetary compensation.

Other displaced persons were resettled in land occupied by squatters which required the new settler to pay for the existing development that included farm structures, coconut trees etc

The displaced people were promised jobs depending on their qualifications where majority were considered for casual jobs while outsiders benefitted from more formal jobs.

There is noise pollution caused by excavators and dust pollution as the forest cover has been depleted to pave way for excavation.

On corporate social responsibility, the company has invested in social amenities such as health centres and schools but locals claim they have been built far away from the affected persons.

In Uganda, the 1998 Land Act and the National Environment Act of 1995 recognize customary interests in land, though the government can acquire land in order to control environmentally sensitive areas, thereby usurping customary land rights of indigenous groups. The National Environment Act does highlight that environmental management should include maximum participation by the people, effectively requiring the consultation of indigenous peoples prior to the gazetting of their land.

Uganda’s 2013 National Land Policy contains very progressive language regarding the rights for minorities, and more specifically for customary land owners. The policy identifies ethnic minorities as “ancestral and traditional owners,” and goes as far as to say that even though ethnic minorities are the “users and custodians of the various natural habitats,” that they are “not acknowledged even though their survival is dependent upon access to natural resources.” The policy acknowledges that the establishment of national parks and development of regions, including through mining and logging, “often takes place at the expense of the rights of such ethnic minorities.” It calls on the government to protect the rights to ancestral lands of ethnic minority groups and give them prompt, adequate, and fair compensation for displacement by government action.

In Karamoja unfulfilled promises to community such as schools, hospitals, boreholes, jobs, scholarships and money in exchange for their compliance abound. Exploration has continued and communities have yet to see the promised benefits that were supposed to help mitigate current and future

3.3. Free, Prior and Informed Consent

States have a duty under international law to consult and cooperate with indigenous peoples through their own representative institutions in order to obtain their free and informed consent. This is supposed to occur before the approval of any project affecting their lands or territories and other resources, particularly in connection with the development, utilization, or exploitation of mineral, water, or other natural resources. This duty is derived from indigenous peoples’ land and resource rights, discussed above. States must also provide effective mechanisms for just and fair redress for any such activities, and appropriate measures shall be taken to mitigate adverse environmental, economic, social, cultural, or spiritual impact.

It is sometimes contended that compulsory acquisition of property or eminent domain takes precedence over free, prior, and informed consent rights. To the contrary, laws regarding compulsory acquisition must, like all other laws, respect human rights including indigenous peoples free, prior, and informed consent rights.

In Karamoja, mining companies have consistently failed to secure free, prior and informed consent from the local communities before embarking on their operations on communal lands.

3.4. Community Participation

Poverty and environmental problems in these regions persist simply because poor people and environmental concerns remain marginalised by and from those in power. Poor people are unable to access resources, services and political processes; in effect, they are excluded from the institutions and benefits of wider society.

Decision making built on the pillars of access to justice, not only gives an opportunity to the public to make informed choices and influence decisions; it also creates a stable and predictable investment environment for business that has a ripple effect on the well-being of the locals.

3.5. The Role of the Church

The church has a cardinal role in defending the rights of the less privileged in society. Over the years, the church has become the voice advocating for social justice and good governance in society. The Catholic Bishops in Uganda issued a communiqué requiring Parliament to put the necessary structures, policy and legislative framework to regulate and manage the mining sector as a priority. The church has also called upon the central government to be transparent at all times when negotiating and signing of the production Sharing Agreements so as to boost the ownership. We believe the church needs to go further than this by using its well established structures in educating the masses on their rights.

4.0. THE LEGAL FRAMEWORK

4.1. Kenya

a) The Constitution of Kenya

The Constitution of Kenya 2010 makes provisions with regard to agreements relating to natural resources which are relevant in ensuring optimum exploration and exploitation of titanium in Kenya. Article 62 (1) (f) defines public land to include all minerals and mineral oils as defined by law and shall be held by the national government in trust for the people of Kenya and administered by the National Land Commission.

In particular, Article 71 of the Constitution provides that every transaction involving the grant of a right or concession by or on behalf of any person including the national government to another person for the exploration of any natural resource in Kenya shall be subject to ratification by Parliament. Parliament is mandated to enact legislation stipulating the classes of transactions subject to ratification.^{^[24]}

The Constitution safeguards the right to property which is relevant for compulsory acquisition of private land in areas minerals such as titanium have been found. It limits the power of the state to deprive a person of property, interest or right in property of any description.^{^[25]} One of the justifications for compulsory acquisition of land is acquisition of land for public purpose or in public interest. Such acquisition must be followed by prompt payment in full of just compensation and right of access to a court of law if the party is aggrieved.

The Constitution binds the state, inter alia, to encourage public participation in the management, protection and conservation of the environment.^{^[26]} Further, the state has a duty to ensure sustainable exploitation, utilisation, management and conservation of the environment and natural resources and ensure the equitable sharing of the accruing benefits. The government is also charged to utilise the environment and natural resources for the benefit of the people of Kenya. This last duty is relevant in protecting the interest of the community in that it challenges the constitutionality of any attempt to use natural resources such as coal for personal or non-public benefits.

b) The Mining Act, 1940

The Act has a gross spectrum of provisions which abet the violations of the individual rights. The Act specifically gives powers to the minister of the Mines to award prospecting licences and have the final decision on determination of any disputes related to the licences.[27]

Instances of forced land acquisitions have been character of the mining trends in the regions in study. The Act requires private owners of lands on which minerals have been found to “give consent”

The “consent” envisaged in the Act has not been explicitly defined and therefore remains an abused power held by the duty bearers. It is widely accepted that information as to the existence of certain minerals in particulars areas may not be the common knowledge of the rural/local land owners and therefore the prospectors only declare the existence of the minerals to the land owners after they have acquired the land by coercion. The land owners therefore end up selling the land at an undervalued price.

Points of concerns in the Act are also in the broad definitions of terms and subject matters. For instance, “mine” includes any open-cast mine, place, excavation or working whereon, wherein or whereby any operation in connection with prospecting or mining is carried on; while, “location” means an area in respect of which mining rights have been acquired under a prospecting right or exclusive prospecting licence and which subsist in accordance with the provisions of this Act;

c) The Mining Bill 2014

The Mining Bill 2014 is a Bill for an Act of Parliament to govern minerals exploration, prospecting, mining, processing and dealings in Kenya. A cursory look at the Bill reveals that it does not address the local communities interests in that it does not adequately provide for accruing benefits to the community, neither does it offer measures to ensure that communities living in mining zones are safeguarded from environmental hazards arising from titanium exploration and exploitation. Additionally the Bill fails to address compensation or resettlement and general land policies concerning land rich in minerals. The Bill ought to regulate the titanium mining industry to ensure the proper and efficient development and use of titanium resources for the benefit of the people of Kwale and Kenya in general.

Employment

Exploring and Mining companies are required to submit a detailed programme for the recruitment and training of citizens of Kenya.^{^[28]} Preference in employment should be made in regard to Kenyan citizens, work on replacing technical non-citizen employees with Kenyans.^{^[29]}

Ownership

In large scale mining, the government is to acquire 10% share capital. Within four years after obtaining license, mining companies are supposed to offload at least 20% of its equity at Local Stock Exchange.

In prospecting, mining, processing, refining and treatment operations, preference should be given to local companies, services, materials and products locally sourced.

4.2. Uganda

a) The Mining Act

Mining activities in Uganda are controlled under the 2003 Mining Act and the 2004 Mining Regulations. The Mining Act does not currently require any form of consent or consultation with local communities prior to the application or acquisition of an exploration license. While it does require a mining lease applicant to negotiate a surface rights agreement prior to the granting of a mining lease, it does not require this for an exploration license application. Ultimately, the law falls well short of protecting free, prior, and informed consent rights.[30]

The mining law specifies that regardless of land ownership, all minerals are the property of the government.[31] While any Ugandan entity can retain the right to search for and extract minerals, all prospecting, exploration, and mining can only be carried out under an appropriate license. In order to participate in mineral exploration, one must acquire a prospecting license. The license is not confined to a specific area and gives the holder a right to look for minerals and to demarcate it by planting “beacons” to indicate to others the area is exclusively booked. A prospecting license is not renewable and is valid for one year. A location license is available to locally resident artisanal miners.

When more than one entity applies for mineral rights over the same land Ugandan law requires that the first person who has marked out the land in question be accorded priority.

When priority cannot be given, the commissioner of the Department of Geological Survey and Mines (DGSM) has discretion to decide who will receive priority.[32]

Entities intending to extract minerals for sale must apply for a mining lease. The application to the commissioner must include:

· a statement giving details of all known mineral deposits in the area, as well as possible and probable ore reserves and mining conditions;

· a technological report on mining and processing techniques to be used by the applicant;

· a statement describing the program of proposed developments and mining operations. This needs to include: the estimated capacity of production and scale of operations, the estimated overall recovery of the ore and mineral products, and the nature of the mineral products;

· a report on the goods and services which can be obtained in Uganda required for the mining operations, and proposals on the procurement of those goods and services;

· a statement on the employment and training of Ugandan citizens; and

· a business plan that forecasts capital investment, operating costs and revenues, type and source of financing, and a financial plan and capital structure.[33]

It is not until a company prepares to apply for a mining lease that Uganda’s law requires proof of communication with the land owners or occupiers. Applicants must state how many owners or lawful occupiers there are for the area he or she intends to mine, include written proof that he or she has reached an agreement with those owners or occupiers,[34] and include written proof that he or she has an agreement, negotiated with broad community support, which clearly quantifies compensation for disruption of the land.[35]

The Mining Act requires the holder of mineral rights to exercise such rights “reasonably” and in such a manner as not to adversely affect the interests of any owner or occupier of the land. However, this has not been interpreted by the courts and it is unclear what may be precisely involved in complying with this provision. The act states that the land owner or lawful occupier is entitled to demand either compensation for disturbance or a share of royalties.[36] The act also stipulates circumstances under which compensation may be paid to owners or persons lawfully occupying land that is the subject of a mineral right, for example for any crops, trees, buildings, etc., that may be damaged in operations. However, the law specifically states that compensation will only be paid “on demand” of the land owner and must be requested within one year of the damage.[37] Given the very limited knowledge of land owners as to their rights under the mining law, it is likely that rightful compensation payments are neglected.

The Mining Act also stipulates how royalties must be allocated to the various stakeholders—80 percent to the central government, 10 percent to the district government, 7 percent to the sub county, and 3 percent to the “owners or lawful occupiers of land subject to mineral rights.”[38] Payments to the community can be quite difficult when there is no bank account or legal entity recognized to receive the money.

5.0. THE MINING COMPANIES PRACTICES IN THE REGION

5.1. The East Africa Mining

East African Mining: Kaabong District East African Mining Ltd. (EAM), a local subsidiary of East African Gold, incorporated in Jersey, holds exploration licenses covering several hundred square miles of Kaabong district.[39] Since June 2012, the junior mining company has been using various prospecting methods to sample soil for gold in the parishes of Lois, Lopedo, Loyoro, Naikoret, and Sokodu, which span four sub-counties in Kaabong.

From the investigations we carried out, it indicates that EAM did not receive, or even seek, the permission or consent of the indigenous land owners prior to undertaking exploration on their land.[40] We interviewed 10 community members in the Kaabong parishes where EAM had been exploring. All of those interviewed said that they were not consulted by EAM about their planned activities prior to seeing them in their community, extracting soil samples. In a phone interview with one of the Company’s official who refused to be quoted, he acknowledged that the company’s consultations had initially been limited and even nonexistent prior to commencing exploration; however, the company worked to improve them over time.[41]

Community members, local government officials, and former employees described EAM’s exploration process damaging gardens.[42] When gardens were damaged by excavators or due to trenching, land owners received some compensation. However, when sampling uprooted just a few crops, there was no compensation.

EAM’s local labor practices were also problematic. This is especially troubling as employment is often touted as the key community benefit to mining operations. According to a former EAM employee, the company began recruiting its 58 contractors on June 8, 2012. This included 40 survey team members, 8 scouting team members, 8 technical and administrative staff, and 2 housekeepers, in addition to its 6 management staff.[43]

All employees were employed casually without contracts and several reported not receiving wages that they were owed. Mistreatment of employees where community members narrated how they witnessed employees being fired, stripped of their uniform and thereby forced to walk home naked.[44]

The management of EAM never furnished us any document detailing their labour practices such as recruitment and work related policies.

5.2. Jan Mangal in Moroto District

Jan Mangal Ltd was incorporated in Uganda on May 5, 2011 by an Indian businessman. Jan Mangal employees arrived in Moroto together with machinery such as excavators and began excavation work without any licence or paperwork on land where another company by the name Mega, already possessed an exploration license.[45]

The community came to know about the license when Jan Mangal arrived. The local people opposed it and it had to take the intervention of the central government officials including at least three parliamentarians representing Karamoja and Engola who brokered a solution in 2012.[46]

On July 20, the company purchased exploration rights from the DGSM to a small plot of land on the Kenyan border in Rupa Sub-county. No meeting was held with the locals to discuss the company’ plans hence raising tension between two communities Matheniko and Tupeth.

Several people in Moroto noted that Jan Mangal’s operations became increasingly reliant on the town speaker to deal with the local community and smooth business relationships with government authorities. The town speaker selected elders to go to Kampala to meet with the company and central government officials. Some community members felt these elders were not appropriate and not representative of the affected communities, rather they were aligned to the speaker. According to two elders who attended, they were each compensated UGSh 200,000 to 300,000 (US$80-120). According to one community member, when the Kampala delegation returned, they gathered the community and said they had accepted the company’s presence in their area. In verbatim, this is what they said, “when investors come we must accept them with one heart and never ridicule them.”

No meeting was ever initiated to disseminate information to the rest of the community on what had been agreed. The agreement was signed by the eight elders as a lease of 21 years with effect from granting the mining lease.[47]

According to one of the community members- Achilla, in terms of benefits to the community, Jan Mangal agreed to employ community members on the mine and providing community members with soil for them to extract gold. So far this has not been honoured. While others aver that if anyone is benefitting from Jan Mangal’s mining, it is the sub-county and municipal officials.

On CSR, the surface rights agreement states that the elders and management of Jan Mangal will later sit to agree on activities that the investor will do for them as part of social responsibility.

5.3. DAO Uganda- Moroto District

DAO Uganda Ltd Is a Ugandan limited liability company incorporated on August 1, 2012 by two businessmen- Mohammed Aoun and Qasim Askari based in Kuwait. It is a subsidiary of the Kuwait based DAO Group.

In Karamoja, DAO acquired two exploration licenses in February and june 2013, both in Rata village which is in area of conflict between Rupa and Katekekile sub-counties of Moroto[48]

The company’s objectives in Moroto are to mine marble dimension stones- large slabs with specific grain patterns- from the mountainside. Ultimately, DAO plans to construct a factory to process and polish stones on site before transporting to Mombasa-Kenya for export.[49]

According to local community members, DAO had at last three meetings in 2013 with community members to explain their plans and try to determine who and how to compensate the genuine land owners who will be affected.

On May 31, 2013, DAO concluded a memorandum of understanding with a group that became known as the “Rata Community surface right owners.” As per the agreement, the company agreed to compensate the community members for the land.

As part from its intention to build a marble factory, some of their proposed CSR activities include constructing a health centre, recognise and encourage artisan miners and help their access to market, train and employ local people, provide scholarships for needy, qualified secondary school students, upgrade and maintain the road and provide water either via a borehole or a well.

According to available data, 36 individuals received UGSh 2,320,000 (US$928) each; two received UGSh 600,000 (US$ 240) each and nine received UGSh 500,000 (US$ 200) each. The compensation for the Rata area marble mining concession according to the agreement totalled UGSh 89, 220,000 (US$35,000). Is the compensation just??

On environmental safety, DAO’s EIA misses some key aspects of the impact of the mining activities on the affected community. Noise pollution and dust to those who live nearby is a major concern.

5.4. Base Titanium

Base Titanium Limited is a wholly owned subsidiary Australian-listed resources company, Base Resources Limited. It entered the Kenyan mining sector by buying off the Kwale mineral sands project from Tiomin Resources Inc in 2010 at a fee of US$ 3 million.[50]

According to the management of Base Titanium, various phases of resettlement have been undertaken since 2006, each conducted according to its own Resettlement Action Plan (“RAP”) prepared and implemented in collaboration with local committees including representatives of directly affected communities.

Compensation was paid for land, agricultural crops, forest trees, structures and graves. Additionally requirements for livelihood replacement strategies and replacement land were provided. These RAPs were prepared in compliance with international best practice as stipulated in the IFC Performance Standards.

Base Titanium is a signatory to the Extractive Industries Transparency Initaitive – a global initiative to ensure transparency in payments between resource companies and their host governments.

The management of Base Titanium provided us with various policies they have put in place and these include; the employment policy, procurement and supply policy, environment policy, communities policy and the health and safety policy. We never had the opportunity to verify the efficacy of these policies.

i) Community Engagement

Community liaison field offices have been established in Magaoni and Kibwaga, population centres adjacent to the lease area.

Base has established a number of committees to act as an interface between the Project and affected communities in various locations:

The Mining Project Liaison Committee acts as the primary channel of communication to affected stakeholders in Msambweni District. It is supported by the Likoni Liaison Committee providing links to communities near the Likoni ship loading facility. The Kwale Liaison Committee to engage with communities affected by the transport corridor between Ukunda and Likoni. Several sub-committees have also been set up to manage community engagement with affected communities in a more direct manner at the mine site (Access Road Committee and Kibwaga Committee) and in Likoni (Kibuyuni Sub-Committee).

ii) Community Programmes and Investment

Community Awareness Presentations – to provide affected communities with Project updates and planned activities. Such presentations are conducted in schools and villages centres.

Community Health & Safety Presentations – an educational component to help communities understand risks associated with Project activities and to advise on mitigating measures.

A major part of Base’s community initiatives is development. This includes:

Livelihood Restoration – Each RAP has a built in livelihood restoration component to address impacts of resettlement. Consultation with directly affected households are undertaken to determine steps required to achieve the intended objectives. These include agricultural programmes and alternative livelihood training such as small and medium sized enterprises that can provide services to the Project.

Replacement Social Infrastructure – As resettlement leads to loss of community infrastructure such as churches, mosques and schools, consultation is carried out in conjunction with the MPLC to identify suitable alternative locations for replacement facilities. It also considers the effects that resettlement has on host communities and identifies the need to strengthen social amenities in the host area.

Community Health – In consultation with district medical authorities, plans are being put in place to promote public health initiatives with emphasis on prevention of HIV/AIDS, malaria and other illnesses of major concern.

6.0. ZAMBIA CASE STUDY

Rounded Rectangle: Environmental Framework
- A framework for responsible development has also been created through publication of the Environmental Protection and pollution Control (Environmental Impact Assessment) regulations, 1997. Key steps in establishing a project as laid down by these regulations are:
- Preparations of a project brief to the Director of Mines Safety describing the site, proposed activities, and all aspects of potential environmental impact;

- The Director may request more information or can forward the project brief to the Environmental Council of Zambia recommending one of the following: rejection, acceptance after submission of a full Environmental Impact Statement, or the project be accepted and allowed to proceed immediately;
- Preparation of an Environmental Impact Statement and its submission to the Director of Mines Safety;
- The Director of Mines Safety submits his recommendations to the Environmental Council which makes the final decision;
- Environmental Impact Statements, if called for, should be updated annually or within fifteen months of the first statement ;
- Environmental audits of projects to be completed annually;
- If a developer finds the provisions of any regulation unduly onerous, he may apply to the Minister or Director of Mines Safety for an exemption from these regulations. The exemption may be granted under prescribed conditions; and
- Developers of large-scale mining projects are to contribute to the Environmental Management Fund for rehabilitation purposes.

Rounded Rectangle: COPPER MINING: ACTIVITIES OF GLENCORE
Mining is the lifeblood of the Zambian economy and Mopani Copper Mines that is 70 per cent owned by Glencore is its beating heart. The London-listed giant has ploughed more than BP 345m into Zambia in 2013 and employs 16,560 people in Mufulira, who in turn have more than 100,000 dependants. Yet Kankoyo, a dense cluster of modest homesteads huddled in the shadow of Mopani’s gargantuan sulphur-belching copper smelter, is struggling to feel the benefits.

Miners are paid a relatively high BP3 per day; too dispute the extent of their financial gain. Decent wages by local standards are diluted by toxic effect of sulphur, which prevents crops from growing and forces families to buy them at market instead.

Of the 16,400 strong workforce who toil six-and-a-half days a week in the rock underneath Mufulira, 50 per cent are ‘not Mopani employees’ but contractors.

On Corporate Social Responsibility (CSR) front, the company provides 50 per cent of clean water around but several townspeople report ill effects after drinking it and children often resort to the open, rubbish filled sewers instead.

A school and gleaming hospital with a state-of-the-art accident and emergency wing and thriving HIV/AIDS programme have been provide. The hospital is free for non-contract staff to use but in only one condition that they must be Mopani employees.

Impacts:
Health
Glencore uses harmful acids to extract copper. Only one of the three safety pumps was ever stalled in the extraction system. Consequently, a damage of this single pump led to severe contamination of drinking water in 2007.
The emission of sulphur at the Mopani mines is 70 times higher than the maximum healthy limit set by the World Health Organisation. Locals suffer toxic rains and respiration problems.

Tax Evasion
5 NGOs filed a formal complaint with the OECD in April 2011 against Glencore and First Quantum for breaching the OECD Guidelines. The complaint was based on an audit report of Mopani Copper Mines by the Zambian Revenue Authorities. The government loses BP 76 million a year because of Glencore’s tax avoidance

Though Zambia is one of the countries in the region that apply the Extractives Industry Transparency Intiative (EITI) standards, the templates used by multinationals prevent scrutiny. It allows another subsidiary of the same mining company, based in another jurisdiction, to make a corrupt payment to a politician in Zambia. It would allow a company within Zambia, created for shell purposes, to be paid for “services rendered”, diminishing tax.

7.0. RECOMMENDATIONS

Implement robust procedures to consult with local people: decision making, built on pillars of access to information, public participation and access to justice not only gives an opportunity to the public to make informed choices and influence decisions, but it also creates a stable and predictable investment for business.

Right to own land: Recognise the communities in both countries as distinct indigenous peoples with rights to their lands and recognise their land rights over land traditionally occupied and use. Correct procedures on compulsory acquisition as laid down in the legislative framework should be followed in a transparent manner in order to obtain their free consent prior to approving any project affecting their lands.

Impact Assessments: There is need for a stronger focus on community impact assessments that are mandated under the Kenyan and Ugandan laws. There is also need for human rights impact assessments.

Evictions: Both governments should ensure that all land evictions or displacements are implemented in accordance with international law particularly the UN Basic Principles and Guidelines on Development-based Evictions and Displacement as well as national legislations that provide for the right to property and adequate compensation in cases of compulsory acquisition.

Adopt International Standards: Both governments should follow good international practice in the management of natural resources. They should begin implementing internationally recognised standards of transparency and accountability including the requirements and recommendations of the Extractive Industries Transparency Initiative (EITI).

Role of Parliament:

The Ugandan Parliament should amend the Land Act to make eligible broad social representation in the composition of communal land associations in order to address a major hurdle for registering certificates of customary ownership.

Amend the Mining Act to include a requirement for clear evidence of free and informed consent from affected communities prior to granting an exploration license and again prior to granting of mining leases.

The Kenyan Parliament should pass the Geology and Mining Bill 2014 currently being debated on the floor of the House with provisions of community participation in the mining sector and revenue sharing from the proceeds of the mines between the mining companies, the national government and the communities where the minerals are found.

Role of the Church

The Church and other faith institutions clearly have a sacred role to play in addressing the conflict and injustices to which mining can contribute. As holders of moral authority within communities, the clergy can support efforts by communities to defend their rights and protect their livelihoods. They can help communities engage effectively in dialogue and negotiations with companies to ensure communities receive appropriate benefits. And they can use their influence to hold companies and governments accountable when things go wrong. Churches, and in particular the Catholic Church, should take up this responsibility in partnership with their communities.

The Judiciary

Disputes arising from compensation and land rights should also have a quick redress in the Land and Environment Court.

Mining Companies

There is need to put structures and frameworks in place to facilitate consultations with the community members. The place of liaison and communal engagement should be mainstreamed. In areas where land is communally owned, the company should seek to engage the community in identifying solutions to health, access to amenities, creation of alternative livelihoods and community labor policies which will ensure mutual co existence and security to both the company and community.

Their presence in the communities should be felt through meaningful corporate social responsibility projects

Seek to reduce environmental pollution by using safe and cleans means of mining i.e. by using sound and dust arresters.

There is need for companies to take health policy covers for the mine workers

Valuation and compensation should not be conducted by internal company experts but should be a documented process in which the government and community negotiators should be involved.

8.0. ANNEXES

QUESTIONNAIRE

CATEGORIES OF PEOPLE TO INTERVIEW:

CATEGORY A: Government Officials

1. Type of minerals/natural resources that exist in the country (particularly in the Karamoja & Kwale area)

2. Contribution of natural resources/extractive industry to the economy (in terms of revenue and employment)

3. Legal & Institutional framework in place to govern the industry (laws that have been passed to govern the sector)

4. Challenges faced in the industry and the proposals for reform if any

CATEGORY B: Mining Companies

1. Period of time engaged in the industry

2. Challenges in the industry (external/internal)

3. Any contribution to society in form of Corporate Social Responsibility (CSR). Is it structured, predictable or ad hoc?

4. Is the environment conducive for operation?

5. How do you describe the relation between your company and the local community?

6. In your own assessment, has the local community benefitted from your activities? If yes, how?

7. Any changes you can propose to the industry? i.e. in the regulatory framework etc

CATEGORY C: Church Leaders)

1. What is the role of the church in management of natural resources/extractive industry?

2. Has the church been involved in any form of advocacy in the management of the extractive industry?

3. What is your position as regards to transparency in the extractive industry

4. Does the church leadership have any role to play in ensuring all stakeholders are involved in managing the extractive industry for the benefit of all?

5. What is the probable cause of poverty in this area, taking into consideration of the wealthy of Natural resources

6. In your opinion who is not playing his/her among the stakeholders in ensuring benefit sharing?

7. Is there (in your knowledge) existence of any benefit sharing policy between mining companies and local people?

8. What role has church played to ensure the locals benefit from these companies?

CATEGORY D: Community Leaders/ CSOs

1. To what extent is the community involved in the management of the extractive industry? Is there any form of participation i.e. from contract negotiation, employment opportunities etc

2. What benefit has the extractive industry offered to the community i.e. proceeds from the mines, CSR, employment opportunities

3. Which environmental effects afflict the community as a result of the activities in the mines? If nay, what is being done to remedy it?

4. Do communities get (if any) enough compensation due to displacement or environmental effects caused by mining?

5. What are the challenges /obstacles that hinder compensation or benefit sharing between communities and mining companies(give options like: Lack of policy framework, high illiteracy levels among the locals, lack of good will from mining companies, politics etc)

CATEGORY E: Displaced Persons

1. Did you directly loose land/property?

2. Was the compensation less than what you lost?

3. Were you informed of government plans to compulsory acquire your land?

4. Were you given enough time to relocate?

5. Were you given alternative land or monetary compensation?

6. How long did it take to be relocated?

7. Was the compensation process fast?

8. Are you comfortable in the new environment?

9. Are there any challenges?

10. Did the mining company involve you in discussing compensation and relocation costs?

11. How has your livelihood improved since the mining company was set in the area?

12. Have you or your close relative benefited either from employment or contracts from the mining company?

[1] www.worldbank.org/en/news/press-release/2012/10/04/despite-global-slowdown-african-economies-growing-strongly-world-bank-urges-countries-spend-new-oil-gas-mineral-wealth-wisely Accessed on 23rd July 2014

[2] http://www.kecosce.org/downloads/KWALE_COUNTY_STRATEGIC_PLAN.pdf

[3] Fairventures Worldwide, “Feasibility Study—Dryland commodities and livelihoods in Karamoja,” January 2013,

http://fairventures.org/wp-content/uploads/2013/01/UGANDA-Dryland-commodities-and-livelihoods-in-Karamojafeasibility-

study.pdf (accessed July 16, 2014).

[4] Ben Knighton, The Vitality of Karamojong Religion (Aldershot: Ashgate Publishing Ltd., 2005), p. 24.

[5] “Waiting for Karamoja to develop: Of Uganda’s uneven development,” Daily Monitor, June 20, 2012,

[6] Museveni Explains Janet’s Posting,” New Vision, March 9, 2009, http://allafrica.com/stories/200903100006.html

(accessed July 16, 2014)

[7] Mrs. Janet K. Museveni, “Karamoja Will Be Transformed Because It Is Part of Uganda,” undated,

http://janetmuseveni.com/karamoja/karamoja_transform.php (accessed July 26, 2014).

[8] “Uganda: Making the most of security and livelihood gains in Karamoja,” IRINnews, October 25, 2011,

http://www.irinnews.org/report/94059/uganda-making-the-most-of-security-and-livelihood-gains-in-karamoja (accessed July 16, 2014).

[9] www.cdca.it/spip.php?article1707&lang=it Accessed on July 26 2014

[10] Fairventures Worldwide, “Feasibility Study,” http://fairventures.org/wp-content/uploads/2013/01/UGANDA-Drylandcommodities-and-livelihoods-in-Karamoja-feasibility-study.pdf.

[11] M.K. Magunda, “Study on Disaster Risk Management,”

http://www.fao.org/fileadmin/user_upload/drought/docs/Karamoja%20Disaster%20Risk%20Reduction.pdf.

[12] “Food insecurity threatens 1/2 million in Uganda’s northeast,” IRINnews, July 10, 2013,

[13] “All peoples shall have the right to their economic, social and cultural development with due regard to their freedom and identity and in the equal enjoyment of the common heritage of mankind,” UNDRIP, art. 26, 32(1); African [Banjul] Charter on Human and Peoples’ Rights, adopted June 27, 1981, OAU Doc. CAB/LEG/67/3 rev. 5, 21 I.L.M. 58 (1982), entered into force October 21, 1986, art. 22.

[14] Ibid., art. 26.

[15] ACHPR, “276/03 Center for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya,” May 2009, para. 227.

[16] United Nations Declaration on Development, art. 2(3); ACHPR, “276/03 Center for Minority Rights Development (Kenya and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya,” May 2009, paras. 278, 279.

[17] ACHPR, “276/03 Center for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya,” May 2009, paras. 283 and 294. “Benefit sharing is vital both in relation to the right to development and by extension the right to own property: Endorois,” para. 294.

[18] ACHPR, “276/03 Center for Minority Rights Development (Kenya and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya,” May 2009, para. 283.

[19] http://www.kenyampya.com/index.php?county=Kwale Accessed on July 26 2014

[20] This is a response obtained from the questions we emailed the management of Base Titanium. We never had time to verify the veracity of the information.

[21] Article 40 of the Constitution of Kenya 2010

[22] Article 40 (3) (b) (i)

[23] Interview with a displaced resident

[24] Article 71(2) of the Constitution of Kenya

[25] Ibid Article 40(3)

[26] Ibid Article 69(1)(d)

[27] (2) Should any question arise as to whether any particular land is excluded under this section, it shall be referred to the Minister, whose decision shall be final and conclusive.

(3) Where any consent required under subsection (1) is unreasonably withheld or the Minister considers that any withholding of consent is contrary to the national interest, the Minister may take such steps as are necessary under the Law relating to the compulsory acquisition of land or rights or interests in land to vest the land or area in question, or rights or interests in such land or area, in the Government or on behalf of the Government; and thereafter such land or area shall cease to be land excluded from prospecting and mining under subsection (1).

[28] Section 44

[29] Section 45

[30] When a company is ready to apply for a mining lease, then an environmental impact assessment is legally required. Those often occur with some basic discussions with the affected community but their consent is not specifically required.

[31] Art. 3 of Mining Act

[32] Articles 6&7 of The Mining Regulations, 2004,

[33] The Mining Regulations, 2004, Art. 41

[34] Article 42 (3) of the Mining Act 2003

[35] Arts 38-42 of the Mining Regulations 2004

[36] Art. 83 of the Mining Act 2003

[37] Ibid…Art.82

[38] Mining Law, Second Schedule.

[39] East African Gold PLC. is a private company incorporated in 2011 primarily to explore and develop gold prospects in

Karamoja. See East African Gold website, http://eastafricangold.com/ (accessed July 28 , 2014); EAM, “Project Brief for

Proposed Drilling & Trenching Operations in Lopedo, Loyoro, Sokodu, Lois & Naukoret Gold Prospects in Kaabong District,”

October 2012, on file with Human Rights Watch, p. vi. It also holds exploration licenses over other areas of Karamoja. See

also East African Gold PLC., “Statement of Particulars of Incorporation,” Jersey Financial Services Commission, November 8,

2012; East African Gold PLC., “Certificate of Incorporation,” November 9, 2012. Jersey, in the Channel Islands, is a “crown

dependency” and is therefore accountable to the queen, but self-governing. It has a corporate tax rate of zero, except for

financial companies. For more on Jersey and its tax laws, see Leah McGrath Goodman, “Inside the World’s Top Offshore Tax

Shelter,” Newsweek.com, January 16, 2014, http://mag.newsweek.com/2014/01/17/jersey-taxes.html.

[40] Phone interview with the CEO of EAM, Dr. Tom Sawyer after writing to him asking a series of questions related to our research. In the course of the interview

[41] Phone Interview with the Company Official

[42] “They entered my garden through the middle and took a soil sample from there…. I asked them not to spoil my crops—a

mix of maize and sorghum—but two or three were uprooted,” Interview with M.S., Lois, Kathile, Kaabong, July 6, 2014.

[43] East African Gold website, http://eastafricangold.com/ (accessed July13, 2014)

[44] This assertion can’t be verified since the management of the company never responded when we sent a request for clarification

[45] Interview with local leaders and journalist

[46] Interview with Mr. Anyuru Geoffrey – a Gulu based lawyer well versed with the agreement

[47] Surface Rights Agreement between Appatod, Lodonga Lokwangoria, Engorlat, Apakerlem, Longara John, Ekamaripus, Thokan Loitakongu, Ocwee Engoriangot, loput Etodongole, Elders of Rupa Sub-county and Katikekile Sub-county in Moroto District

[48] See Spatia Dimesnion, “Uganda mining cadastremap” 2013: www.flexicadastre.com/uganda

[49] http://www.newvision.co.ug/news/637464-kuwait-investors-to-construct-cement-factory-in-budaka.html Accessed on July 8 2014

[50] http://af.reuters.com/article/investingNews/idAFJOE61O0LC20100225

AMECEA Justice and Peace

Pages

Wednesday 1 October 2014

RIGHTING THE INJUSTICES IN THE EXTRACTIVE INDUSTRY.

ABBREVIATIONS

ACKNOWLEDGEMENT